N, a landlord, locks H out of the rented flat to force payment of rent. H has an established continuing…

Section 126(1) covers voluntary obstruction preventing a person from proceeding in a direction in which they have a right to proceed, so these facts establish "Wrongful restraint"; H is not held within circumscribing limits, which rules out "Wrongful confinement". In Sovarani Roy the Calcutta High Court recognised that locking out a tenant could fall within the corresponding IPC rule but acquitted because the tenancy right was not proved, so the right of access is material. No threatening gesture or use of force on H is shown, so neither "Assault without any threatening gesture or preparation" nor "Criminal force merely because a lock is used" applies.